Fresenius Medical Care AG & Co. KGaA, a leading provider of products and services for people with chronic kidney failure based in Bad Homburg, Germany, has settled allegations with both the SEC and DOJ that it engaged in bribery in myriad ways in myriad countries. Despite its self-report, the company did not receive full cooperation credit and is required to retain a compliance monitor for two years. Fresenius will also pay more than $200 million in disgorgement and penalties. We analyze the case. See “What the $850 Million MTS Settlement Signals About FCPA Enforcement, Disclosure and Cooperation” (Apr. 3, 2019).